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Federal Court of Australia · [2026] FCA 458

Turner v Chandler Macleod costs

A Federal Court Fair Work costs decision about settlement releases, unreasonable relitigation and a $20,000 lump-sum costs order.

Federal Court of Australia17 Apr 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • The Fair Work jurisdiction is usually protective on costs, but it is not a free pass for hopeless relitigation.
  • A Federal Court Fair Work costs decision about settlement releases, unreasonable relitigation and a $20,000 lump-sum costs order.

Use this to check

  • Fair Work costs are restricted, but s 570 still allows costs in specific cases.
  • A release deed can be decisive if later proceedings try to reopen settled claims.
  • Self-represented litigants can still face costs if a case is hopeless or unreasonable.

Decision snapshot

  1. 1

    What happened

    • This costs judgment followed Turner v Chandler Macleod Group Limited [2026] FCA 139.
    • In that earlier decision, the Court struck out Mr Turner's claim against Chandler Macleod and made other orders in a proceeding involving employment, long service leave, injury and settlement-history issues connected with the Mt Arthur coal mine.
    • Chandler Macleod then sought a lump-sum costs order of $20,000.
    • Fair Work Act proceedings are usually subject to a limited costs regime under s 570, but costs can be ordered where proceedings were instituted vexatiously or without reasonable cause, or where an unreasonable act caused the other party to incur costs.
  2. 2

    What the court had to decide

    • The Federal Court had to decide whether the s 570 Fair Work Act costs exceptions were enlivened, and whether Chandler Macleod should receive a lump-sum costs order after the claim against it had been struck out because a settlement deed released the relevant claims and no proper basis to set aside the deed had been pleaded.
  3. 3

    What the court decided

    • The Court ordered Mr Turner to pay Chandler Macleod's costs in the fixed amount of $20,000 and otherwise dismissed the proceedings.
    • The Court was satisfied the claim against Chandler Macleod had been instituted without reasonable cause and that prosecuting it was unreasonable.

Practical impact

Practical read

  • The Fair Work jurisdiction is usually protective on costs, but it is not a free pass for hopeless relitigation.
  • Settlement deeds and releases should be drafted carefully, explained properly and stored with the surrounding dispute file because they may later decide whether a fresh claim can proceed.

Useful next steps

  • Fair Work costs are restricted, but s 570 still allows costs in specific cases.
  • A release deed can be decisive if later proceedings try to reopen settled claims.
  • Self-represented litigants can still face costs if a case is hopeless or unreasonable.
  • A bald assertion that a settlement deed is illegal is not enough to avoid its effect.
  • Lump-sum costs can be used to avoid a longer costs assessment process.

Practical read

This case is a useful companion to the earlier Turner decision because it shows what can happen after an employment claim is struck out. Many business owners know that Fair Work proceedings are often described as a no-costs jurisdiction. That is broadly true as a starting point, but the judgment shows the limits of that protection.

The Court looked at the settlement history. The earlier judgment had found that the Chandler Macleod deed released the relevant claims and that the attempt to set it aside was not properly pleaded beyond a bald illegality allegation. On that footing, the Court found the claim against Chandler Macleod was instituted without reasonable cause and that continuing it was unreasonable. The applicant was self-represented, but that did not prevent a costs order.

For employers, contractors and workers, the practical point is document quality. If a dispute is settled, the deed should clearly identify the parties, released entities, released claims, confidentiality obligations and any opportunity for legal advice. If a later dispute arises, the file should make it easy to show what was resolved. For anyone thinking about reopening a settled matter, the case is a warning that the Fair Work costs rule has exceptions where a claim is hopeless or unreasonable.

Checks to run

Key points

  • When settling an employment dispute, record exactly which claims and entities are released.
  • Keep evidence that the person had time and opportunity to get legal advice before signing.
  • If defending a repeat claim, put the release deed and prior litigation history in one chronology.
  • Do not assume Fair Work proceedings can never lead to costs.
  • If seeking lump-sum costs, prepare evidence that explains the amount and why it is proportionate.

Key takeaways

  • Fair Work costs are restricted, but s 570 still allows costs in specific cases.
  • A release deed can be decisive if later proceedings try to reopen settled claims.
  • Self-represented litigants can still face costs if a case is hopeless or unreasonable.
  • A bald assertion that a settlement deed is illegal is not enough to avoid its effect.
  • Lump-sum costs can be used to avoid a longer costs assessment process.

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